Secret Pesticides Documents Revealed

In July wildlife NGOs were dismayed, confused and indeed angered by the Government’s decision to allow the use of banned pesticides proven to cause great harm to wild bees.

It seemed an incomprehensible decision in light of the growing evidence that neonicotinoids routinely harm bumblebees and solitary bees and concerns, expressed even in the Government Chief Scientist’s annual report, that neonicotinoids may not actually be improving crop yields.

Now, new Freedom of Information disclosures have revealed that in response to NFU demands Defra agreed to let pesticide companies sell farmers neonicotinoid treated oilseed rape seeds in four counties, despite the NFU:-

1) failing to provide any direct evidence that using the pesticides would improve either crop yields or crop establishment by controlling Cabbage stem flea beetle numbers;.

2) stating that if neonicotinoid seed treatments had been used in 2014 (as the NFU had requested) they would not have helped with the problems some farmers experienced with flea beetles that autumn;

3) clearly stating that alternative pesticides were available.

Decision Timeline

An EU wide ban on using three neonicotinoid seed treatments on flowering crops was introduced at the start of 2014, because the regulator, the European Food Standards Authority, had confirmed that they posed a risk to bees.

A Member State may legally authorise a derogation to allow the use of a banned pesticide, but only for ‘a period not exceeding 120 days’, ‘for limited and controlled use’, and where ‘necessary because of a danger which cannot be contained by any other reasonable means’.

Almost immediately the NFU requested a derogation to allow the continued use of neonicotinoid seed treatments on all UK oilseed rape. Defra did not approve the application and it was withdrawn in July 2014.

The NFU submitted the same request again in 2015. On 18th May the Defra Chief Scientist Prof. Ian Boyd set out a long list of short-comings in the application, highlighting particularly the absence of evidence that the neonicotinoid ban had actually caused a significant problem, and the absence of evidence that neonicotinoid seed treatments would solve any localised problems caused by Cabbage stem flea beetles. Some of the Chief Scientist’s comments were cutting “There is very little information, other than some broad statements, to support the claim that this will have an effect upon yield.” and “The NFU submission makes almost no effort to link its assertions to verifiable, published evidence or provide appropriate, balanced interpretation of the evidence”.

On the 20th May the Government’s Expert Committee on Pesticides met behind closed doors, but with pesticide industry employees invited and present, to discuss the NFU application. The Committee concluded that for control of flea beetles there were “no alternative chemicals authorised” and hence the application met the criteria of being a ‘danger which cannot be contained by any other reasonable means’ but that the application was not for a ‘limited and controlled’ use so they would not support it.

The NFU then submitted a second application to use neonicotinoids on oilseed rape, relating only to Suffolk.

Over 500,000 people signed a 38 Degrees petition asking the Government to keep the ban on neonicotinoids and protect British bees and pollinators; it was presented on the 7th July to No.10 Downing Street.

On the same day the secret application was discussed behind closed doors at the Government’s Expert Committee on Pesticides. According to an ECP official Defra wanted the public to be kept in the dark “to enable Government to have the time and space to consider applications for emergency authorisations without having to provide interim comment or provoking representations from different interest groups whose views on the issue are well-known”. The Committee accepted that the application was sufficiently evidenced for flea beetle and limited in scale, but suggested the applicant should consider if restriction to Suffolk addressed all farms/fields at greatest risk.

It was announced in the farming press on 22nd July that Defra had agreed to bypass the neonicotinoid ban on oilseed rape in four eastern counties.

Defra had capitulated to NFU pressure without waiting to find out how good the yields were from first oilseed rape crop grown without the seed treatments. As the harvest came in over the following two weeks it became apparent that without neonicotinoids there had been a bumper national crop, well above average yields – in the end 3.6-3.8t/ha compared with ten year mean of 3.4t/ha.

On the 20th August a scientific paper published by Government Agency Fera showed, firstly that there was a link between the use of a neonicotinoid pesticide and honeybee colony losses, and secondly that neonicotinoids were not providing consistent yield benefits to oilseed rape; Government had been aware of this data since January 2013.

The NFU Application

It is clear from the document that the Chief Scientist’s initial concerns about the weakness of the evidence presented were not resolved. There are no data, studies or scientific references provided to evidence claims that the ban on oilseed rape had reduced yields, and no new evidence that neonicotinoid seed treatments would be an effective way to reduce flea beetle populations. Indeed the NFU admits in relation to the high levels of flea beetle seen in autumn 2014 that “Had the 2014/15 Emergency Use Approval been given, the problems seen in the east and south east of England would not have been prevented.” A startling statement in direct opposition to the claimed purpose of the application – this should have set Defra alarm bells ringing, but was not highlighted in the subsequent opinion expressed by the Chief Scientist on 8th July.

The application also states that there are a ‘few chemical products to control [CSFB] infestation levels” and lists pesticides that can be used to combat aphids that spread a virus called TuYV – quite clearly establishing that the (unproven) ‘danger’ could be ‘contained’ by ‘other reasonable means’. This failure to meet the legal criteria should alone have resulted in the perfunctory rejection of the application. The deviation was further compounded by the Government concurrently approving a neonicotinoid (Acetamiprid) spray to control flea beetles.

In justifying that neonicotinoid seed treatments would protect oilseed rape from flea beetles the NFU application makes the following claim:-

“In the 2014/15 planting season a number of studies have examined the impact of CSFB in the establishment of the OSR crop in the UK. Studies from the HGCA and independent research organizations have demonstrated that CSFB populations impacted on crop establishment. Critically and as expected the majority of these areas demonstrated increased plant establishment when the OSR seed has been treated with a neonicotinoid seed treatment.”

This statement is vague, but there was a HGCA (AHDB) report produced in August comparing oilseed rape crops that had, and had not, been seed treated with neonicotinoids. However this study reported that neonicotinoids did not improve yields and did not report any difference in establishment rates – it would appear that the NFU was confused or misleading in referring to this study as providing evidence that supports the application, it does the reverse. It is, in any case, well known that small differences in “plant establishment” don’t usually translate into yield differences at the end of the year.

Environmental Injustice

In Prof Ian Boyd’s response to the first application he states “The same level of scrutiny and standards need to be applied to the evidence of efficacy as is being applied to that of negative effects on the environment and, at present, this does not appear to be happening.” He is quite right, the imbalance in justice highlighted is huge, the level of proof that is required to ban a pesticide in order to protect the environment is in effect ‘beyond all reasonable doubt’ – vast tomes of published scientific papers showing statistically significant results in vitro, in the lab, in the field and across whole countries are still met with calls of ‘not proven’ – while here a decision, claimed necessary to protect farmers, has been taken to un-ban a pesticide with more evidence available in the application to dis-prove, than to prove, the claims – and more evidence out in the real world that would also suggest that this derogation will not provide significant benefit to farmers (but will harm the environment).

One might hope that the pesticide regulators were carefully examining the mounting evidence that neonics are harming populations of beneficial insect predators such as ground beetles and ladybirds, and are leaching into, and destroying, aquatic ecosystems, and that they are diligently considering if a complete ban on neonicotinoids it is now the only rational response. Instead we find the regulators are sat around a table with the pesticide companies, poring over an incomprehensible mish-mash of industry claims and assumptions described by the Chief Scientist as “an advocacy document” and conspiring to hurriedly unpick hard won environmental protection measures.

In conclusion

From the evidence in the public domain, it seems clear, and even the NFU admit, that the flea beetle problems of 2014/5 would not have been resolved by neonicotinoid seed treatments. It also appears that the NFU did not address the Defra Chief Scientist’s concerns:- no new evidence was presented to support the claim that neonicotinoid seed treatments provide yield benefits; nor was evidence presented that showed that the high yields in the first year of the ban would have been any higher had neonicotinoid seed treatments been used. Furthermore the application provides evidence that there are alternative pesticides available, hence the criteria for an emergency derogation were explicitly not met.

The decision to allow the use of neonicotinoid insecticides on oilseed rape in the Eastern counties of England appears to have been about as far from an evidence or science based decision as it is possible to get. The imbalance between securing protection of the environment and protection of pesticide industry profits appears bigger than ever, and again it looks as if the NFU and Defra are deeply in the pockets of the agrochemical industry.

Friends of the Earth have initiated a Judicial Review of this decision; the evidence available suggests they may have a compelling case.

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